NCHR Public Comment on FDA Voluntary Sodium Reduction Goals

January 13, 2025                                                                                                                                      FDA-2014-D-0055


To the FDA Leadership:

Thank you for the opportunity to submit comments on the U.S. Food and Drug Administration’s
(FDA’s) draft guidance for industry on Phase II voluntary sodium reduction targets for
commercially processed, packaged, and prepared foods.

The National Center for Health Research is a nonprofit think tank that is dedicated to bridging
the gap between scientific evidence and public policies that affect health and safety. Although
we focus primarily on the safety and effectiveness of medical and consumer products, we also
are concerned about other strategies to improve the health of adults and children.
The research is clear about the risks of sodium in the typical U.S. diet, and we generally support
the FDA’s efforts to encourage industry-wide sodium reduction. The FDA’s proposal for 3-year
(Phase II) targets for industry across 163 food categories are a step in the right direction, and
we support FDA’s efforts toward reducing average sodium consumption to meet the
recommended guidelines of 2,300 mg/day.

However, anyone who reads nutrition labels on popular foods can see that current strategies are
not working. There are enormously high levels of sodium in many popular foods that Americans
do not think of as “salty” and therefore do not bother to read their sodium content, such as
frozen meals, breads, and soups, including food that is advertised as healthy or “low salt.”

We therefore recommend the following:

1. The FDA should set more stringent Phase II targets for maximum sodium per
serving. This should be significantly lower than the 2,750-mg/day goal in the
Proposed Guidance. Even if industry fully complies with that goal, the result would be
far from the 2,300 mg recommended daily limit. To save more lives, the FDA should set
lower targets and move more quickly to meet recommended levels.

2. The FDA should more actively engage the food industry to publicly urge
companies to commit to lower sodium targets. The food industry needs stronger
incentives to voluntarily reduce sodium in their products, and making public those goals
and achievements (or lack thereof) is one useful strategy. The FDA and other HHS
agencies also need to find more consistent ways to bring positive attention to food
companies and restaurant chains that make substantial progress toward these important
goals. For example, products should not have names, labels, or advertising that imply or
state that they are healthy if they are high in sodium.

3. The FDA should set mandatory sodium reduction targets if Phase II voluntary
targets are not met. If voluntary targets are not met, it is time for the FDA to implement
mandatory targets. This is not radical; 19 other countries already have mandatory
sodium reduction targets in place. Although it would be time-consuming to switch to
mandatory targets, it is likely that if the FDA proposes mandatory targets that would
increase compliance with voluntary targets.

In conclusion, it is currently extremely difficult for Americans to significantly reduce their sodium
consumption because sodium levels are so high in so many foods sold in groceries and
restaurants. As a public health agency, the FDA has an obligation to ensure lower sodium
levels in foods sold in the U.S. The food industry has not stepped up despite widespread
knowledge that sodium is harming the health of many Americans. For that reason, it is essential
that the agency do more to provide incentives for companies selling processed, packaged, and
prepared foods to significantly lower sodium content and work with those companies to achieve
that goal. Lives are at stake, and we urge the FDA to act quickly on these recommendations.

Sincerely,

Diana Zuckerman, Ph.D.
President
National Center for Health Research